Chlorinated Paraffins White Paper Now Available

JULY 12, 2017

ILMA has published a White Paper in key developments related to EPA’s approval of pre-manufacture notifications for certain chlorinated paraffins (CPs).

The White Paper notes that the approval is a big “win” for CP manufacturers and processors, including ILMA members, and goes on to highlight several aspects of the approval for the membership that will require specific action to remain compliant with applicable laws and regulations.

First, members should anticipate using more Chemical Abstract Service (CAS) numbers on their product literature and Safety Data Sheets (SDS), as there will be ten new CP substances put on the Toxic Substances Control Act (TSCA) Inventory as a result of EPA’s action.

Second, the White Paper outlines the requirements imposed by OSHA’s Hazard Communication Standard 2012 (HCS 2012), that mandates that Safety Data Sheets (SDSs) and container labels be updated within three and six months, respectively.

The CP substances are also subject to TSCA 12 (b) export notification requirements. If any company, including an ILMA member, either ships the raw material (i.e., CPs) to another jurisdiction or incorporates the CPs into a mixture and exports the finished formulation to another country (e.g., Canada), the reporting requirements attach and notification to EPA must be given.

Reporting entities must provide specific information to the Agency that is outlined in more detail in the White Paper.

Members that utilize CPs as a component of their metalworking fluid (MWF) formulations or as an additive in other lubricants should consult the White Paper and work closely with individual CP suppliers, regulatory compliance staff, and legal counsel to ensure the company is continuing to utilize the substances in a lawful manner.